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The Commissioner determined a deficiency of $388.96 in the income tax of Turner for 1948. Turner (H), and W filed a joint return. H’s name had been selected by chance from a phone book, and he was called on April 18, 1948, and was asked to name a song playing on a radio station. H gave the correct name and then was given the opportunity to name a second song for the grand prize. H got it right and was awarded a number of prizes including two round-trip first-class steamship tickets for a cruise from New York to Buenos Aires. The prize was for one ticket, but if H were married, W got one too. The tickets were not transferable and were basically good only for one year from the date of the prize. H reported the income on the return of $520 representing the two tickets. The Commissioner increased the ticket accounting to $2,220, the retail price of the tickets. As part of a deal with the steamship company, H traded the two first-class tickets and got four tickets between New York and Rio. The actual transaction represented income of $1,400. The Turners (P) petitioned the court for review.

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